Tennessee's secondary violations:
When Tennessee hired Lane Kiffin to replace long-established football coach Phillip Fulmer in 2008, the UT compliance staff launched a campaign to "fully educate the staff on all aspects of NCAA rules," according to the school's response to February's Notice of Allegations.
Because a number of the coaches, including Kiffin and his father, defensive coordinator Monte Kiffin, gathered most of their experience at the professional level, a refresher course was in order.
From the day Kiffin was hired to the day he abruptly left for the same position at Southern Cal, UT compliance provided the football staff with "no fewer than 135 rules-education items." Those items included everything from in-person meetings to emails to monthly compliance newsletters.
As detailed in the university's 190-page response to its NCAA Notice of Allegations, which was filed May 20 and provided Friday to the News Sentinel, it was that kind of documentation that UT used to help largely shift the burden to Kiffin and his former staff for the two major violations levied against the Vols' football program.
Kiffin, along with the various recruiting violations that were lumped into one, all-encompassing major violation, faces a charge of failing to promote an atmosphere of compliance within the football program and failing to monitor the activities regarding compliance of several of his assistant coaches.
All told, UT faces 12 major violations that were discovered during a 21-month investigation. UT, which has already self-imposed two years of probation and various recruiting restrictions in football and men's basketball, and the former coaches involved with the violations continue to await a ruling from the NCAA Committee on Infractions.
Though it let Kiffin off the hook for two infractions involving former assistant coach David Reaves, UT stood behind its compliance staff's efforts to control the one-year coach's behavior when it pertained to impermissible phone calls and bringing a recruiting intern with him on a trip to a Florida high school.
"To the extent that he could have prevented the violations from occurring but failed to do so, the University agrees that Kiffin failed to adequately monitor his own activities and the activities of members of his staff in those two instances," the response reads.
Kiffin and his staff made 16 impermissible phone calls to five different recruits between Jan. 3, 2010 and Jan. 9, 2010. Three of the players — Brandon Willis, Seantrel Henderson and Ahmad Dixon — ended up elsewhere, while the other two, whose names are redacted, are current Vols players.
Though it was an open contact period, Kiffin and his staff had been urged not to contact these particular players. Because of numerous redactions throughout the document, it is unclear why exactly the coaches could not reach out to the players.
According to the response, UT associate athletics director for compliance Brad Bertani, on Dec. 2, 2009, in response to a query from the football staff, relayed instructions to coordinator of football operations Kyle Strongin to inform the coaches not to contact the players.
"I vividly remember having those conversations with them leading up to (redacted)," Bertani said in a Nov. 16, 2010, interview with NCAA enforcement officials. "In fact, I thought it was a good sign that they were asking me all these questions.
"It was very clear that the only people that they could talk to was the parents. And that was if they were very careful about it."
Strongin, in an interview just days before UT received its Notice of Allegations, confirmed that he delivered the message.
In response to a Jan. 5, 2010, question from the staff about contacting the players' parents, Bertani relayed an interpretation one day later that OK'd that type of contact, but reiterated that it could not contact the players.
Kiffin made two impermissible calls to the players within the following 48 hours.
Because it was an open contact period, the university's call log software, Comply & Verify, did not flag the calls. Since June 2010, UT has employed a more advanced monitoring system from ACS Athletics.
The NCAA was originally prompted to investigate UT's football program after a violation involving Kiffin and then-recruiting intern Steve Rubio popped up on the SEC's radar.
On an Oct. 12, 2009, evaluation visit to St. Thomas Aquinas High School in Ft. Lauderdale, Fla., Rubio, who is now the Vols' Director of Player Personnel, accompanied Kiffin and entered the school. Rubio, a St. Thomas Aquinas alum who was not certified to recruit off campus at the time, did not enter any of the other high schools on the trip.
After his interview with NCAA enforcement officials on March 10, 2010, Rubio submitted a written statement indicating that UT senior associate athletic director David Blackburn told him and Kiffin that Rubio was not permitted to enter any of the schools. Blackburn confirmed the discussion during his interview with NCAA investigators, and said the conversation occurred via telephone on the eve of the trip.
Kiffin, in an interview with UT and the NCAA enforcement staff, said he considered it a "rare circumstance" for Rubio to "see his old buddies...his old coaches and teachers." Both Kiffin and Rubio said Rubio did not make contact with any recruits.
Throughout the investigation, UT implemented a number of punitive actions against the football program. Among the restrictions was a nearly 10-month ban (Dec. 18, 2009-Sept. 1, 2010) on recruiting players from St. Thomas Aquinas High. Also, non-coaching staff members are permanently restricted from recruiting-related travel.
Though UT agreed that Kiffin failed to monitor his coaching staff or promote an atmosphere of compliance in the two aforementioned violations, it cleared him on an unclear violation that centered on Reaves because Reaves "acted on his own and without notice to Kiffin." This particular violation associated with Reaves is heavily redacted.
The school also completely disputed an allegation that Reaves urged an unidentified, currently enrolled student to call and text recruits because the report is "lacking both in documentary evidence and supporting statements from the involved parties."